Jerome J. and Ann T. Klawitter - Page 2

                            T.C. Summary Opinion 2003-50                              


                               UNITED STATES TAX COURT                                


              JEROME J. KLAWITTER AND ANN T. KLAWITTER, Petitioners v.                
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 7491-01S.             Filed May 12, 2003.                   


               John W. Johnson and Brian A. Mills, for petitioners.                   
               W. Lance Stodghill, for respondent.                                    


               CARLUZZO, Special Trial Judge:  This case was heard pursuant           
          to the provisions of section 7463 of the Internal Revenue Code in           
          effect at the time the petition was filed.  Unless otherwise                
          indicated, subsequent section references are to the Internal                
          Revenue Code in effect for 1993, 1995, 1996, or 1997, as                    
          appropriate.  The decision to be entered is not reviewable by any           
          other court, and this opinion should not be cited as authority.             






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